CE Marking Advice: Technical Documentation
When I first posted my blog on CE marking advice the British Toy and Hobby Association provided a wide range of excellent and, more to the point, free resources. I referred to those resources repeatedly in my blog. It has come my attention that they have since removed those documents and apparently charge for access to them. As such I’ve decided to post my own versions of the technical documentation that you will need to conform to EU safety standards.
Firstly, a disclaimer. I am not an expert in these areas. I am an independent games designer with a little bit of experience and a game successfully imported and entered onto the market. However, these directives are intended to be those that non-experts can fulfil, it is a system of self-certification. What that means is that only one person is responsible for your certification, not me, or any paid expert, but you. This is one source of information, there are many and I suggest you check several. The regulations do change and I cannot guarantee that any information here is entirely up to date. However, these forms are potentially good starting point for your own documentation. In all cases, this advice should only be considered to apply to games consisting of cards, wooden, resin, metal and plastic components. If your game as electrical elements, liquids, scented elements, things to eat or anything that might be considered out of the usual in a small tabletop game, please, get better advice.
Your technical CE marking documentation should consist of five documents, one of them will be the technical documentation from your testing centre, which is the most important part and I’ve covered in other blogs. The other parts are your statement of conformity, bill of materials, markings documentation and risk assessment.
Statement of Conformity
This should be pretty self-explanatory. Just to say, in the example I’ve not included all the details of our factory’s address or processes, because they’re not really mine to publicise. Your factory or manufacturer should be able to give you a list of these details, particularly if you explain that you need them for technical documentation. You don’t need to know what lithograph printing is (although you should) you just need to say what was used.
Bill of Materials
Again, not too complex, the numbering systems here such as Issue number and parts number are your own, no need to get fancy, your first game is Issue number 1, the parts start from 1 and increase as expected. You only need to list parts that are substantially different in substance separately, so a set of cards of the same size and type can all be listed together. Accessibility means, can people get to it without wrecking the game. So for example if you had a game with one of those pop-o-matic dice, the dice would not be accessible. Method of compliance should, for you, be ‘Testing’ in all cases. There are others (SDS, DoC, TRA) but they should not apply to you.
Markings and warning decisions
This one is a little more complex, it’s a list of all the warnings etc. that you are required or have chosen to put on your game. I’ll start from the top with the explanations of the non-obvious parts. Economic Operator Role, that’s who is taking the role as the economic operator, if you’re self-publishing your Kickstarter or owner of your own small independent, that’s you. Source is the reason that you think the warning is needed, in most cases this will be TSD for the Toy Safety Directive, Directive 2009/48/EC Safety of Toy. In a few it might be your Risk Assessment. Format restrictions, if the warning label is something standardized that you downloaded like the CE mark or the no under 3s mark the answer is yes, if not, its none. Rationale is one that you should just put ‘Clearly Visible’ for. There are some toys that have the marks essentially hidden or attached on separate or removable labels, this shouldn’t apply to you.
The traceability markings are a legal requirement under the Toy Safety Directive, and really every product sold in the EU has an equivalent in its directives. You need to put your name and address on the product, technically on all parts of the product (and your technical report should pick that up), but just the box is pretty standard. I’ve left two blank lines for Importer’s Identification and Importer’s Address. I am currently living in a country that is part of the EU. Those who are not, which may include me in the near future, need to list the name and address of their importer on their product, which is to say, the person or company who receives it in the EU prior to handing it on to the end user. If you are an independent outside of the EU self-fulfilling in the EU this will clearly be a tricky one to answer and I honestly don’t know how best to go about filling it in, never having had the need to find out. Should I figure it out post Brexit, rest assured I will post a blog.
Your Safety Assessment is something that I at least have a little professional training in thanks to the London Fire and Emergency Planning Authority. The essence of a Risk Assessment of this type is to think of all the things that could go wrong when playing your game and explain what you did to make sure they won’t, then think of all the things that couldn’t go wrong and explain why they can’t (within reason, a sense of humour or exaggeration is not best appreciated here).
You game has three elements that could hurt people, the game itself and its elements, where they are when they play it, and how they act when they play it. The first part your testing should have covered and will be a risk that occur that you have mitigated, the second part should be things that your game will control by its very nature.
For the first set of risks, those contained within the game, they will centre on the things that your testing has covered. That is to say, your game catching light, shattering into pointy shards or flaking off horrible poison. Even then, don’t just say that you tested it, if your game is unlikely to get put into people’s mouths, say that and say why you think it. If its for smart grown people who aren’t going to be getting drunk or silly during play, mention it.
As for environmental risks, you have most likely covered those by virtue of your game design. As an example, remember when people kept walking into traffic playing Pokemon Go! at the height of its popularity? Can your game be played without a mid to large sized table? If not, you’ve protected your players against walking into traffic during play. Do players need to communicate complex information? If so, brilliant they can’t play the game somewhere that’s too loud to hear a smoke alarm going off. In short, think of where your game has to be played simply by virtue of how you designed it. Is that place a safe and secure, quiet and well-lit room? Then because of your design you’ve made something with a whole bunch of safety features, this is a section that is a bit of a gift for tabletop game designers. Remember, people have to write these for other toys and games that do not have the advantages of needing to be played in a safe environment, so you have the advantage of explaining the supremacy of quiet indoor play here.
The final major area of risk comes from the behaviour of people. This can be slightly more of an issue depending on the nature of the game in question. Games can require that cards be snatched under time pressure from across a table or that hard wooden pucks be flicked or thrown across a table. If your game is the sort that has a lot of hard thinking then you have again, designed in safety features here. If people are unlikely to get boisterous, drunk or vigorous during play these are all safety features. If you do require that cards be snatched at speed, how have you set-up conditions made this safer for players? If you have players throwing or flicking things how have you ensured that they don’t peg each other out with them?
In essence, it is almost certain that playing your game is a highly safe activity. A safety assessment is your chance to explain why.
Hopefully these forms should assist in creating and maintaining proper technical documentation to support your CE marking.